National Association of ACOs Privacy Policy

Effective Date: October 1, 2016

Overview We take your privacy very seriously and will treat all of your information with care and respect. This Privacy Policy describes your privacy rights regarding the National Association of ACOs (NAACOS) collection, use, storage, sharing, and protection of your personal information on our website at www.naacos.com and in connection with the products and services we provide to you online, such as electronic newsletters, webinars, web-based listservs, online forums, and other online products and services (the “Service”).

Please read this Privacy Policy carefully to understand how we will treat your information before you provide us with any information about you.

BY USING OUR SERVICE, YOU ARE ACCEPTING AND CONSENTING TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY (INCLUDING AS CHANGED FROM TIME TO TIME). IF, FOR ANY REASON, YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP USING OUR SERVICE IMMEDIATELY.

Collection and Use of Personal Information and Other Information Throughout this Privacy Policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person. In order to provide you with information and services, we may ask you to provide us with some personal information.

User content such as written materials, submissions, comments, questions, photos, videos, sounds, or other multimedia

Communications between you and us and/or other users or third parties on the Service (e.g., account, technical, and security notices, changes/updates to features of the Service, messages) or in relation to our products and services

Device and software information (e.g., the type of mobile device and associated hardware and software information, the browser used to access our web service)

You may pay for our products or services or pay fees (e.g., membership fee, conference fee) on our website using a credit or debit card. We use third-party payment card processing companies engaged by us to process payments, including payments made via our website. These third parties have committed to us to process your payment card information in a secure, PCI compliant manner. Your credit card information is processed and retained by these third parties and will not be passed on to us. We do not store your payment card information in any way.

Use of Cookies and Image Tags Cookies are small amounts of information stored in files within your device. We may use session cookies (which expire once you close your app or device) and persistent cookies (which stay on your device until you delete them) to store your preferences and personal information, identify you and maintain your signed-in status, and provide you with a more personal and interactive experience. We may also use beacons which are typically small graphic objects or pixels that are embedded in a screen view or web page. We offer certain features that are available only through the use of cookies. You are always free to decline cookies if your device permits. However, if you decline cookies, you may not be able to use certain features of the Service.

Your device may enable you to indicate your preference as to whether you wish to allow us to collect personal information about your online activities over time and across different devices, apps, websites, or online services. We believe that there is currently no consistent industry standard for how to interpret and respond to these preference settings. Consequently, at this time the Service does not respond to the preferences you may have set in your device regarding the collection of such personal information, and we may continue to collect personal information in the manner described in this Privacy Policy. In addition, other parties may collect personal information about your online activities over time and across different web sites when you use the Service. This policy does not apply to and we are not responsible for those other parties. Please see the section of this policy entitled “How We Share Your Information” for more detail on how we interact with third parties with respect to your information.

Use of Your Information As a general rule we use your information, including personal information, to provide the Service. However, during the process of developing and troubleshooting the Service, it may be necessary to look at pieces of your information to improve the Service or resolve a problem or dispute. Also, when you write us to request support, our customer support representatives may look at your information in order to assist you. We may also access and use your information to compare information for accuracy and verify it with third parties or to comply with applicable law or legal process.

No one at NAACOS has access to your credit card information. We do not store credit card details in our databases or systems. We store your information that we collect on servers located in, and process your personal information in, the United States.

Monitoring User Activity We may monitor user activity on the Service and our systems. For example, we may monitor user activity in order to ensure the Service is operating correctly. We may also use this information to support you when you write us about an issue you are trying to resolve so we can see the history behind your information and to develop and improve the Service.

Managing Your Information If you are a registered user, you may review, update, correct or delete your personal information by making changes to your “Profile.” If you are unclear about how to do this or have concerns, contact us at [email protected].

We may communicate with you at various times, with administrative emails or phone calls, about transactions, products, and service announcements, customer service responses and promotional emails like special offers, newsletters, and updates. You can choose to stop receiving promotional emails at any time simply by changing your preferences, unsubscribing through the applicable feature of the Service, or using an email’s unsubscribe function. You may not opt out of receiving administrative messages or customer service responses. If you have agreed to receive marketing communications through interactions with our partners, you must change your communication preferences with them directly.

If you choose to invite others to use the Service, we ask you for your friend’s email and possibly their name. NAACOS or our service providers may store this information for the purpose of sending introductory emails. Your friend may contact us at [email protected] to request that we remove this information from our database.

How We Share Your Information NAACOS will not sell, rent, or lease your personal information to others except as described in this Privacy Policy. We share your personal information in the following ways:

We will not sell your personal information, but we may disclose your contact information to our affiliates, partners, and/or conference sponsors.

We may disclose your personal information to help you make payments on our website, including to third-party payment card processing companies.

We employ various third parties to run the Service (e.g., hosting service). These third parties operate components of the Service’s infrastructure and may have access to your personal information and information about how you use the Service (e.g., access statistics). These third parties will not be permitted to sell your personal information.

We work with various third-party solutions (e.g., list serve providers, webinar platform providers). In these cases we will share your personal information with the third-party solution providers. Information shared with a third-party solution provider is subject to their privacy policy. We do not control the privacy policies of these third parties and we encourage you to review their privacy policies.

When we identify a co-brand partner for a site or event, you agree that we may share contact information and transaction data (excluding credit or debit card numbers) with that partner. Information shared with a co-brand partner is subject to their privacy policy. We do not control the privacy policies of co-brand partners and we encourage you to review their privacy policies.

We use third-party service providers to help measure our content and advertising effectiveness and to serve ads on our behalf and on behalf of other third-parties. These ads are shown across the Internet. We may share some anonymous, aggregated demographic information with some of these service providers, but we do not share any personally identifiable information except as specified in this privacy policy. These third party service providers may place cookies or web beacons on our websites, but we do not permit them to collect personal information (e.g., email, phone, etc.) in this process.

We also access non-personal information from third parties to improve the Service. For example, we access information about your location, determined from your IP address or mobile device location information, to personalize your experience.

We may also use third-party analytics providers to evaluate how the Service is used and accessed, including by you. We may also access information from third parties that provide further analytical data about you. We use analytics information to improve the effectiveness of the Service, make the Service easier to use, and provide you with a better experience on the Service.

If we are involved in a business transfer (merger, acquisition, combination or sale of any or all of our assets), your information may be transferred, but we will require the surviving or successor company to initially abide by this policy with respect to your personal information and you will receive prior notice if your personal information will be used contrary to this policy following the transaction.

If we are required by law or legal process, we may provide your information to law enforcement or a third party.

Children’s Privacy The Service is not intended for and is not directed toward children. We do not provide the Service to anyone under the age of 18. Furthermore, we do not target our products and services to children under 18 nor will we ever knowingly communicate with anyone under 18. If you believe we might have any information from or about a child, please contact us at [email protected].

Security and Retention The security of your information is important to us. We store our own information in the Service and feel that the service is safe to use for any person age 18 and over.

The Service uses SSL/TLS to secure transmission of data between our servers and your device. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are encryption technologies that provides secure communications over the Internet. They do this by verifying that the server to which you are connected is actually the one it claims to be. They also encrypt all transactions between the parties communicating. Encryption is the scrambling of information as it is transmitted over the Internet to protect your confidentiality. Personal and credit card information passing between your computer and Service is encrypted. This means that while your information is in transit it is scrambled so that only NAACOS and the service providers we leverage to run the Service can reassemble your information in its original text format.

No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee the absolute security of your personal information or other information. If you have any questions or concerns about security, contact us at [email protected].

We retain information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our terms of service and take other actions permitted by law.

Third Party Sites The Service may integrate with or contain links to other websites, apps, and services. Those third party websites, apps, and services have their own privacy policies and terms of conditions that we do not control. We encourage you to review these third-party terms and contact the third party with any questions you may have. We are not responsible for the privacy practices or other actions of these third parties.

Notice to California Residents If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by NAACOS to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at [email protected].

Changes If we decide to change this Privacy Policy, we will post the changes on this website, and if there is a material change to our privacy policy for any reason, unless you have opted out of email communications from NAACOS, we will notify you promptly by sending an email to an email address we have on file for you.

Questions If you have any questions about this Privacy Policy, please contact us at [email protected].